UK to EU VAT Guide 2026 — IOSS, Rates & Customs
Since Brexit, the UK is a “third country” as far as the EU is concerned. Every parcel you ship from the UK to an EU customer is an import into the EU. That means import VAT, customs declarations, and a completely different set of rules to anything you deal with domestically.
This page covers what makes the UK situation distinct from other non-EU sellers. For the underlying EU mechanics that apply to all non-EU sellers, the detailed sub-guides cover everything you need:
- Selling to EU Consumers (B2C) — IOSS registration, charging destination-country VAT at checkout, monthly returns, the €150 threshold, and the new €3 customs duty from July 2026.
- Non-Union OSS for Digital Services — How UK SaaS and digital businesses handle EU VAT with a single registration.
- Selling to EU Businesses (B2B) — Reverse charge mechanism, VIES validation, zero-VAT invoicing, and UK return reporting.
- EU Selling Setup Checklist — Step-by-step setup including UK-specific intermediary requirements and platform guides.
For the generic EU framework that applies to all non-EU sellers, see the Selling to EU Customers overview.
Why Brexit Makes This Different
Section titled “Why Brexit Makes This Different”Before 1 January 2021, UK businesses selling to EU customers were treated as intra-EU sellers. Distance selling thresholds applied. UK VAT registrations were recognised across the EU.
That is no longer the case. Since Brexit:
- The UK is treated as a third country by EU customs — the same as the US, Australia, or any other non-EU nation
- Every shipment from Great Britain to the EU is legally an import
- Import VAT applies at the EU border on all shipments, regardless of value
- UK VAT numbers (GB prefix) are not visible on the EU’s VIES database
- The EU’s €10,000 cross-border distance-selling threshold does not apply to UK sellers
This means UK sellers have the same obligations as any other non-EU seller — but with the added complexity of being a country that used to operate under EU rules and may have historical assumptions that no longer hold.
There Is No Threshold for UK Sellers
Section titled “There Is No Threshold for UK Sellers”This catches businesses out. The EU has a €10,000 cross-border threshold, but that only applies to EU-based sellers shipping between EU member states. As a UK (non-EU) seller, there is no minimum. You must comply with EU VAT rules from your very first EU sale.
This applies even if your turnover is well below the UK’s £90,000 registration threshold. EU obligations and UK obligations are independent systems. You can be below the UK threshold and still have EU obligations.
UK VAT Registration and EU Obligations
Section titled “UK VAT Registration and EU Obligations”Your UK VAT registration status (£90,000 threshold) and your EU obligations are completely separate:
| UK VAT status | EU selling obligation |
|---|---|
| Below £90,000 threshold, not registered | Still must comply with EU VAT rules from first EU sale |
| Registered for UK VAT | Still must register for IOSS separately — UK registration does not cover EU |
| Voluntarily registered for UK VAT | Same as above |
The only domestic VAT registration that interacts with EU selling is if you register in an individual EU country directly — but that is rare and separate from IOSS.
Practical implication: if you are a small UK business below the £90,000 threshold that starts selling to EU consumers, you have EU VAT obligations before you have domestic UK ones. IOSS registration is likely your first VAT registration of any kind.
Northern Ireland — A Special Case
Section titled “Northern Ireland — A Special Case”If your business is based in Northern Ireland (not Great Britain), significantly different rules apply. Under the Windsor Framework, Northern Ireland remains within the EU’s VAT system for goods:
- NI businesses can register for IOSS directly through HMRC — no EU intermediary needed
- NI businesses have XI-prefix VAT numbers that appear on VIES
- Sales from NI to the EU are treated as intra-EU movements for goods, not imports
- NI businesses may use the OSS (One Stop Shop) scheme instead of IOSS for eligible goods
- From 1 April 2026, HMRC also accepts NI-based intermediary registrations acting on behalf of non-EU sellers
If your business is in Northern Ireland, your EU selling obligations are significantly simpler than for Great Britain-based sellers. In particular:
- You do not need a private EU intermediary — HMRC can handle your IOSS registration directly
- Your XI VAT number is visible to EU business buyers on VIES, so B2B reverse charge works in the same way as it does for EU-based suppliers
- You are not treated as a “third country” for goods — you are inside the EU VAT system for goods movements
GB vs XI VAT Numbers
Section titled “GB vs XI VAT Numbers”This distinction matters for B2B sales:
GB-prefix VAT numbers (Great Britain sellers):
- These are UK VAT numbers
- They are not listed on VIES (the EU’s VAT validation system)
- If an EU business buyer looks you up on VIES, they will not find you
- This does not prevent reverse charge — the EU buyer simply treats your sale as an import from a third country and self-accounts for import VAT. The practical effect on the buyer is the same.
- You cannot use a GB VAT number as proof of EU VAT registration
XI-prefix VAT numbers (Northern Ireland businesses):
- These are issued by HMRC for Northern Ireland businesses under the Windsor Framework
- They are listed on VIES — EU buyers can validate them
- They allow NI businesses to participate in intra-EU supply rules for goods
The GB vs XI distinction matters most when you are selling to EU businesses who want to validate your registration. GB-based sellers should explain to EU business customers that GB VAT numbers are third-country tax registrations, not EU VAT numbers, and that the buyer should self-account for import VAT under their normal third-country import procedures.
Stripe Payment Links and EU Sales
Section titled “Stripe Payment Links and EU Sales”If you take orders via Instagram or other social media and send customers Stripe payment links, these do not work for EU B2C sales. Stripe payment links:
- Do not know the customer’s country at checkout (so you cannot charge the correct EU VAT rate)
- Cannot capture EU VAT numbers for B2B reverse charge
- Do not include your IOSS number on customs declarations
For EU B2C orders taken through social media, direct the buyer to your Shopify or WooCommerce store, create a draft order and send that as the payment link, or use an invoicing tool that generates VAT-compliant documents. The IOSS number must flow through your store’s checkout and into the customs declaration — Stripe payment links break this chain.
VAT Rates by EU Country
Section titled “VAT Rates by EU Country”You must charge the destination country’s standard VAT rate on most goods. Full rate table and country-specific guides:
| Country | Standard Rate | Reduced Rates | Guide |
|---|---|---|---|
| Austria | 20% | 10%, 13% | Coming soon |
| Belgium | 21% | 6%, 12% | Coming soon |
| Bulgaria | 20% | 9% | Coming soon |
| Croatia | 25% | 5%, 13% | Coming soon |
| Cyprus | 19% | 5%, 9% | Coming soon |
| Czech Republic | 21% | 12% | Coming soon |
| Denmark | 25% | — | Coming soon |
| Estonia | 24% | 9%, 13% | Coming soon |
| Finland | 25.5% | 10%, 14% | Coming soon |
| France | 20% | 5.5%, 10%, 2.1% | UK to France |
| Germany | 19% | 7% | UK to Germany |
| Greece | 24% | 6%, 13% | Coming soon |
| Hungary | 27% | 5%, 18% | Coming soon |
| Ireland | 23% | 9%, 13.5%, 4.8% | Coming soon |
| Italy | 22% | 4%, 5%, 10% | Coming soon |
| Latvia | 21% | 5%, 12% | Coming soon |
| Lithuania | 21% | 5%, 12% | Coming soon |
| Luxembourg | 17% | 3%, 8%, 14% | Coming soon |
| Malta | 18% | 5%, 7% | Coming soon |
| Netherlands | 21% | 9% | UK to Netherlands |
| Poland | 23% | 5%, 8% | Coming soon |
| Portugal | 23% | 6%, 13% | Coming soon |
| Romania | 19% | 5%, 9% | Coming soon |
| Slovakia | 23% | 5%, 10% | Coming soon |
| Slovenia | 22% | 5%, 9.5% | Coming soon |
| Spain | 21% | 4%, 10% | UK to Spain |
| Sweden | 25% | 6%, 12% | Coming soon |
Rates last verified: May 2026. Always verify against the European Commission’s rate database before filing.
UK Seller Compliance Checklist
Section titled “UK Seller Compliance Checklist”The minimum setup for a UK seller regularly shipping to the EU:
- IOSS registration via an EU intermediary (or via HMRC if Northern Ireland) — budget €40–300/month for an intermediary (B2C guide)
- Shopify/WooCommerce configured for EU VAT — destination-country rates at checkout with your IOSS number
- IOSS-aware shipping carrier — carrier must transmit the IOSS number electronically
- Monthly IOSS returns — filed by your intermediary
- B2B reverse charge process — VIES validation and compliant invoicing, UK VAT return reporting in Box 6 and Box 8 (B2B guide)
- Budget for the €3 customs duty from July 2026
- UK VAT registration — still required separately for domestic obligations if over £90,000 (UK Domestic VAT Guide)
For a detailed step-by-step checklist including platform setup and carrier configuration, see the EU Selling Setup Checklist.